Conflict of Interest Policies

Our leadership firmly believes in the following principles.

It is the policy of the Investment Recovery Association (“Association”) the its Board of Directors and Association committee members must act at all times in the best interest of the Association and shall not derive any personal profit or gain, directly or indirectly, by reason of his or her participation in the leadership of the Association. The purpose of this policy is to help inform the Directors and Association committee members about what constitutes a conflict of interest, assist in identifying and disclosing actual and potential conflicts, and help ensure the avoidance of conflicts where necessary.

1. Directors and Association committee members have a fiduciary duty to conduct themselves without conflict to the interests of the Association. Directors and Association committee members must subordinate personal, individual business, third-party, and other interests to the welfare and best interest of the Association.

2. Conflict of interest arises when a Director or Association committee member has an actual or potential business, professional or personal interest such that his or her loyalty and fiduciary duty to the Association could be impaired. Examples of actual or potential conflicts of interest could include, but are not limited to, engaging in any of the following activities:

Participating directly or indirectly in any decision which has resulted or could result in personal benefit;

Receiving salary payment, unreasonable expense reimbursements, loan, gifts, free services, or any other fees from or on behalf of any person or organization engaged in any transaction with the Association;

Owning stock in excess of 1% or holding debt or other proprietary interest in any third part dealing with the Association;

Holding office, serving on the board,participating in management or being otherwise employed or formerly employed in or by any third party dealing with the Association;

Receiving remuneration for services with respect to individual transactions involving the Association;

Using the time, personnel and equipment, supplies, or property of the Association for purposes other than the Association’s approved activities, programs and purposes;

Appropriating for personal gain any business or other opportunities relating to the business of the Association;

Using the confidential information of the Association for personal gain or to compete with the Association;

3. The Board of Directors shall appoint an Association Management Team consisting of three member representatives on the Board of Trustees, one associate member representative on the Board of Directors and the Executive Director.

4. All Directors and Association committee members shall disclose fully any actual and/or potential conflicts of interest to the Association Management Team annually through the annual disclosure form and promptly thereafter whenever an actual or potential conflict becomes apparent to the individual. All Directors and Association committee members having a continuing responsibility to scrutinize their outside business and personal interests for potential conflicts and to promptly disclose the same. This policy is to be construed broadly, rather than narrowly, and any doubts as to the application of this policy should be resolved in favor of disclosure.

5. The disinterested members of the Association Management Team shall confer with counsel and make a determination as to whether a conflict exists and what subsequent action is appropriate, if any. A member of the Management Team or Association’s counsel shall review with the director or committee member the outcome of the Management Team discussion. The Association Management Team shall inform the Board of such determination and action, if action is necessary. The disinterested member of the Board shall retain the right to modify or reverse such determination and action, and shall retain the ultimate enforcement authority with respect to the interpretation and application of this policy.

6. Any interested Directors or Association committee members must be recused from participation in debates and voting on any matter in which there may be a perceived or actual conflict of interest.

7. On an annual basis, all Directors and Association committee members shall be provided with a copy of this policy an required to complete and sign the acknowledgment and disclosure form attached. All completed forms shall be provided to and reviewed by the Association Management Team, as well as all other conflict information provided by Directors and Association committee members.